Free Motion for Extension of Time to File - District Court of Delaware - Delaware

Case 1 :04-cv-01430-GMS Document 14 Filed 07/21/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
IN RE: ANC RENTAL CORPORATION, et al.
Bankruptcy Case No. O1-11200
Debtors
ANC RENTAL CORPORATION, et al.
Appellant Civil Action No. 04-1430
v.
DALLAS COUNTY, ET AL.
Appellees
APPEAL FROM THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
HONORABLE MARY F. WALRATH
APPELLANT’S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
TO THE HONORABLE UNITED STATES DISTRICT COURT:
Appellants ANC LIQUIDATING TRUST, (Appellants), pursuant to the Federal Rules of
Bankruptcy Procedure and Local Rules of Civil Practice and Procedure of this Court, and
respectfully move for an extension of time to tile its Brief herein, and in that connection, would show
the following:
1. This is Appellant’s first request for an extension of time to file the Appe1la11t’s Brie£
SLI sss616v1/01 1002.00001

Case 1:04-cv-01430-Gl\/IS Document 14 Filed 07/21/2005 Page 2 of 3
2. On October 8, 2004, the United States Bankruptcy Court for the District of Delaware
issued a Memorandum Opinion and signed an Order in Bankruptcy Case No. O1-1 1200, In Re: ANC
Rental Corporation, et al., Adversary Proceeding N0. 04-51204, ANC Rental Corporation, et al. v.
Dallas County, et al. Appellant ANC Rental Corporation appealed from the Order in this case.
3. The Appellant perfected this appeal by filing its Notice of Appeal on October 18,
2004. Following mediation of this matter, the dispute remaining unresolved, the Court approved a
Stipulation and Order Re Post-Trial Briefing Schedule dated July 1, 2005. (the ABriefing Schedule
s).
4. Pursuant to the Briefing Schedule, Appellant’s brief is due to be filed on
July 22, 2005.
5. Appellants’ counsel of record has, over the last several weeks leading up to the
current filing deadline, been required to devote significant time and attention to several other
pending legal matters in which this firm is involved. Each of these cases has unavoidably consumed
substantial amounts of counsel’s available time, and delayed completion of Appellant’s Brief herein.
6. As a result, Appellant respectfully requests an additional twenty-one (21) days in
which to complete and file Appellant’s Brief] with similar extensions ofthe deadlines for filing of
Appellees’ Brief and Appellant’s Reply Brief thereafter.
7. The undersigned attorney for Appellant has conferred with Appellees’ attorneys and
confirmed that this motion is unopposed by all appellees.
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Case 1:04-cv-01430-G|\/IS Document 14 Filed 07/21/2005 Page 3 of 3
WHEREFORE, Appellant respectfully requests that the Court extend the tiling deadline for
Appel1a11t’s Brief to August 12, 2005, with Appe1lees’ Briefs thereafter due on September 9, 2005,
and Appe1lant’s Reply Brief on September 30, 2005.
Dated: July 21, 2005.
Respectfully submitted, 1 ‘
\ i /
/s/Jose h Gre A
Joseph Grey (N 8) 1
Thomas G. Wha : · r. (No. 40
STEVENS & LEE, P.C.
1 105 North Market Street, 7th Floor
Wilmington, DE 19801
Telephone: (302) 654-5180
Telecopier: (302) 654-5181
J.M. HARRISON & ASSOCIATES
1035 C Street, Suite 200
Floresville, Texas 781 14-2223
Telephone: (830) 393-0500
Telecopier: (830) 393-4941
ATTORNEYS FOR APPELLANT S
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